The UK’s Extended Producer Responsibility (EPR) for packaging fundamentally shifts the full net cost of managing household packaging waste from taxpayers to producers. According to the UK House of Commons Library, under the revised scheme introduced in April 2025, producers must now cover all costs of collecting, sorting, recycling, and disposing of packaging waste, replacing the older system in which producers paid only a small proportion of these costs.
This cost recovery model is designed so that local authorities (LAs) are reimbursed for their operating costs, using payment calculations based on tonnage, operational data, and local characteristics. Importantly, these payments are not designed to fall if producers reduce packaging volumes. Instead, LAs receive a basic payment covering their estimated costs, which are largely fixed because waste collection systems (vehicles, staffing, depots) cannot easily scale down when packaging is reduced.
This creates a structural tension: producers are incentivised to innovate to reduce packaging, as EPR fees are closely tied to material weight and recyclability. But because local authority waste-management costs remain broadly fixed, reductions in packaging do not reduce the overall funding requirement. Instead, the fee base shrinks, forcing fee rates upward the following year to meet the same total LA cost. The 2026 operational guidance confirms that fees will increasingly be eco-modulated under the Recyclability Assessment Methodology (RAM), meaning producers must redesign packaging annually merely to maintain cost parity. This is really challenging for adhesives and sealants where the packaging has a technical function.
This can create a “spiral of innovation”: each reduction in packaging weight results in are calibration of fees that may erase the cost savings producers expected, because local authority costs are constant and must still be recovered. This dynamic is reinforced by the fact that the scheme is expected to raise over £1 billion annually for waste-management costs, a figure driven by LA requirements, not producer behaviour.
Is the UK EPR/RAM Framework Fatally Flawed?
If the aim is environmental improvement, EPR may work; but if the aim is a fair cost-signal that rewards genuine producer efficiency, the current fixed-cost structure undermines that purpose and may indeed push producers toward unsustainable packaging minimisation purely to offset rising fees.
BASA represents the £1.7 billion UK and Irish adhesives and sealants sector, promoting innovation, compliance, and sustainability while supporting business growth and industry standards. Visit http://www.basa.uk.com
